New Entrant Report U.S. Office of Government Ethics; 5 C.F.R. part 2634 Form Approved: OMB No. (3209-0001) (January 2018) Executive Branch Personnel Public Financial Disclosure Report (OGE Form 278e) Filer's Information Kudlow, Lawrence A Assistant to the President for Economic Policy, Director of the National Economic Council, White House Date of Appointment: 04/02/2018 Other Federal Government Positions Held During the Preceding 12 Months: None Electronic Signature - I certify that the statements I have made in this form are true, complete and correct to the best of my knowledge. /s/ Kudlow, Lawrence A [electronically signed on 05/15/2018 by Kudlow, Lawrence A in Integrity.gov] - Filer received a 45 day filing extension. Agency Ethics Official's Opinion - On the basis of information contained in this report, I conclude that the filer is in compliance with applicable laws and regulations (subject to any comments below). Other review conducted by U.S. Office of Government Ethics Certification Kudlow, Lawrence A - Page 1
Data Revised 06/29/2018 Data Revised 06/25/2018 Data Revised 06/13/2018 Data Revised 06/12/2018 Data Revised 05/16/2018 Kudlow, Lawrence A - Page 2
1. Filer's Positions Held Outside United States Government # ORGANIZATION NAME CITY, STATE ORGANIZATION TYPE POSITION HELD FROM TO 1 Kudlow & Co., LLC Fairfield, Connecticut Corporation CEO 4/2001 3/2018 2 Committee to Unleash Prosperity New, New Non-Profit Founder/Chairm an of the Board 3/2015 3/2018 3 CNBC New, New Corporation Senior Contributor 3/2014 3/2018 4 Westwood One Washington, Corporation Radio Host "The Larry Kudlow Show" 6/2010 3/2018 5 Creators Syndicate Hermosa Beach, California Corporation Syndicated Columnist 4/2001 3/2018 6 Independent Women's Forum Washington, Non-Profit Board Member 6/2002 3/2018 7 Catholic Advisory Board Ave Maria Mutual Funds Bloomfield Hills, Michigan Non-Profit Board Member 6/2005 3/2018 8 Penguin Random House New, New 9 Guggenheim Partners, LLC New, New 10 Mark Asset Management New, New 11 Iridian Asset Management, LLC Westport, Connecticut Corporation Book Author 9/2013 9/2017 Corporation Consultant 4/2015 3/2018 Corporation Consultant 6/2000 3/2018 Corporation Consultant 8/2001 3/2018 Kudlow, Lawrence A - Page 3
2. Filer's Employment Assets & Income and Retirement Accounts # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1 Kudlow & Co., LLC See Endnote N/A Owner's draw (business income) $782,000 1.1 "JFK and the Reagan Revolution: A Secret History of American Prosperity " Portfolio / Penguin Random House (value not readily ascertainable) N/A Contract amount (balance paid during reporting period) $16,830 1.2 Institute for International Research, Inc. - January 23, 2017 N/A honorarium $32,000 1.3 RBC Capital Markets - January 31, 2017 N/A honorarium $15,000 1.4 Ameriquest Transportation Industry - February 16, 2017 N/A honorarium $25,000 1.5 The Clearing House - February 7, 2017 N/A honorarium $15,000 1.6 Topco - March 3, 2017 N/A honorarium $25,000 1.7 The Money Show - February 8, 2017 N/A honorarium $25,000 1.8 Morgan Stanley - April 7, 2017 N/A honorarium (conference call fee) $10,000 1.9 Great Point Partners - April 6, 2017 N/A honorarium $15,000 1.10 Greene Institute - April 3, 2017 N/A honorarium $13,500 1.11 PriceWaterhouseCoopers, LLP - April 20, 2017 1.12 The Construction Industry Roundtable - May 16, 2017 N/A honorarium $15,000 N/A honorarium $20,000 1.13 Deloitte Services LP - May 23, 2017 N/A honorarium $30,000 Kudlow, Lawrence A - Page 4
# DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1.14 Prudential Annuities - May 23, 2017 N/A honorarium (conference call fee) $7,500 1.15 National Association of Corporate Treasurers - June 1, 2017 N/A honorarium $15,000 1.16 Neuberger Berman - June 21, 2017 N/A honorarium $15,000 1.17 National Retail Federation - July 18, 2017 N/A honorarium $25,000 1.18 Strategas Research Partners, LLC - November 14, 2017 N/A honorarium $30,000 1.19 SVP Global - October 18, 2017 N/A honorarium $12,000 1.20 National Assoc for Industrial and Office Properties - October 19, 2017 1.21 North American Spine Society - October 25, 2017 1.22 Investment Company Institute - November 9, 2017 N/A honorarium $40,000 N/A honorarium $27,500 N/A honorarium $15,000 1.23 Newsmax Media/Google - October 12, 2017 N/A honorarium $25,000 1.24 Strayer University - November 4, 2017 N/A honorarium $10,000 1.25 Mizuho Investor Conference - December 5, 2017 1.26 Bank of America/Merrill Lynch - November 28, 2017 1.27 Natixis Middle Market Lending/CLO Forum - September 29, 2017 N/A honorarium $5,000 N/A honorarium $30,000 N/A honorarium $10,000 1.28 Financial Times Forum - October 24, 2017 N/A honorarium $15,000 1.29 Guggenheim Investments - December 1, 2017 N/A honorarium $20,000 Kudlow, Lawrence A - Page 5
# DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1.30 NY Historical Society - February 1, 2018 N/A honorarium $1,000 1.31 Legatus Summit - January 25, 2018 N/A honorarium $30,000 1.32 TriState Capital - February 8, 2018 N/A honorarium $20,000 1.33 Seton Hall University - February 15, 2018 N/A honorarium $2,000 1.34 The Money Show - February 8, 2018 N/A honorarium $25,000 1.35 "American Abundance" Am. Heritage (value not readily ascertainable) 2 Consumer Discretionary Select Sector SPDR Fund (ETF): XLY N/A Yes $15,001 - None (or less than $201) 3 ishares U.S. Telecommunications (ETF): IYZ Yes $1,001 - $15,000 None (or less than $201) 4 ishares U.S. Technology (ETF): IYW Yes $15,001-5 Consumer Staples Select Sector SPDR Fund (ETF): XLP Yes $15,001-6 Energy Select Sector SPDR Fund (ETF): XLE Yes $1,001 - $15,000 7 Financial Select Sector SPDR Fund: XLF Yes $15,001-8 Health Care Select Sector SPDR Fund (ETF): XLV Yes $15,001-9 Industrial Select Sector SPDR Fund: XLI Yes $15,001-10 Materials Select Sector SPDR Fund: XLB Yes $1,001 - $15,000 11 Real Estate Select Sector SPDR Fund: XLRE Yes $1,001 - $15,000 12 Utilities Select Sector SPDR Fund: XLU Yes $1,001 - $15,000 Kudlow, Lawrence A - Page 6
# DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 13 SPDR S&P Dividend (ETF): SDY Yes $50,001 - $100,000 14 U.S. bank #1 (cash account) See Endnote N/A $15,001 - $1,001 - $2,500 None (or less than $201) 3. Filer's Employment Agreements and Arrangements None 4. Filer's Sources of Compensation Exceeding $5,000 in a Year # SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 1 Kudlow & Co., LLC Fairfield, Connecticut 2 Committee to Unleash Prosperity New, New 3 CNBC New, New 4 Westwood One Washington, 5 Independent Women's Forum Washington, 6 Penguin Random House New, New 7 Guggenheim Partners, LLC New, New Serve as Chief Executive Officer; provide personal services to clients Consulting services to found organization and serve on board. On-air personality, commentator Radio program host Board member Book author Management and financial consulting services Kudlow, Lawrence A - Page 7
# SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 8 Mark Asset Management New, New 9 Iridian Asset Management, LLC Westport, Connecticut 10 Neuberger Berman New, New Management and financial consulting services Management and financial consulting services Management and financial consulting services; speaking engagement 11 Fayez Sarofim Houston, Texas Management and financial consulting services 12 US Bank Washington, 13 Jackson International Life Ins Nashville, Tennessee 14 FBL Financial Group Scottsdale, Arizona 15 CliftonLarsonAllen Orlando, Florida 16 Wisconsin Manuf. & Commerce Madison, Wisconsin 17 The Money Show Orlando, Florida s 18 PricewaterhouseCoopers New, New 19 Nat'l Rural Utilities Coop New, New 20 Nat'l Assoc of Corporate Treasurers New, New 21 Nat'l Rural Utilities Coop Seattle, Washington 22 Prudential Securities New, New s s (conference call) Kudlow, Lawrence A - Page 8
# SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 23 Lexington Partner LP New, New 24 US Trust Warren, New Jersey 25 Guggenheim Investments Baltimore, Maryland 26 Marcum LLP New, New 27 Sterling National Bank Tarrytown, New 28 RBS Securities New, New 29 Institute for International Research Hollywood, Florida 30 RBC Capital Markets New, New s 31 Ameriquest Transportation Industry Orlando, Florida 32 The Clearing House New, New 33 Topco Palm Beach, Florida 34 Morgan Stanley New, New 35 Great Point Partners New, New 36 Greene Institute Palm Beach, Florida 37 The Construction Industry Roundtable Washington, (conference call) Kudlow, Lawrence A - Page 9
# SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 38 Deloitte Services LLP Chicago, Illinois 39 Prudential Annuities New, New 40 National Retail Federation Washington, 41 Strategas Research Partners LLC London, Outside U.S. 42 SVP Global New, New (conference call) 43 National Association for Industrial and Office Properties Phoenix, Arizona 44 North American Spine Society Orlando, Florida 45 Investment Company Institute New, New 46 Newsmax Media Washington, 47 Google Washington, 48 Strayer University New, New 49 Bank of America Boca Raton, Florida 50 Merrill Lynch Boca Raton, Florida 51 Natixis Middle Market Lending New, New Kudlow, Lawrence A - Page 10
# SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 52 Financial Times New, New 53 Legatus Orlando, Florida 54 TriState Capital Philadelphia, Pennsylvania 55 Catholic Advisory Board Ave Maria Mutual Funds Bloomfield Hills, Michigan Advisory board member 5. Spouse's Employment Assets & Income and Retirement Accounts # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1 self-employed (art studio) N/A income from the sale of paintings 2 ishares Russell 2000 Index (ETF): IWM Yes $1,001 - $15,000 None (or less than $201) 3 SPDR S&P Dividend (ETF): SDY Yes $15,001-4 U.S. bank #2 (cash account) See Endnote N/A $1,001 - $15,000 None (or less than $201) 6. Other Assets and Income # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1 Consumer Discretionary Select Sector SPDR Fund (ETF): XLY Yes $15,001 - Kudlow, Lawrence A - Page 11
# DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 2 ishares U.S. Technology (ETF): IYW Yes $50,001 - $100,000 3 ishares Core S&P Small-Cap (ETF): IJR Yes $15,001-4 ishares Select Dividend (ETF): DVY Yes $15,001-5 Energy Select Sector SPDR Fund (ETF): XLE Yes $15,001 - $1,001 - $2,500 6 Health Care Select Sector SPDR Fund (ETF): XLV Yes $15,001-7 Industrial Select Sector SPDR Fund: XLI Yes $15,001-8 Materials Select Sector SPDR Fund: XLB Yes $1,001 - $15,000 None (or less than $201) 9 SPDR Dow Jones Industrial Average (ETF): DIA Yes $15,001-10 SPDR S&P 500 (ETF): SPY Yes $500,001 - $1,000,000 $5,001 - $15,000 11 U.S bank #3 (cash account) N/A $1,001 - $15,000 None (or less than $201) 12 U.S bank #4 (cash account) N/A $1,001 - $15,000 None (or less than $201) 7. Transactions (N/A) - Not required for this type of report Kudlow, Lawrence A - Page 12
8. Liabilities # CREDITOR NAME TYPE AMOUNT YEAR INCURRED RATE TERM 1 Citibank Credit Card $15,001-2 Bank of America Credit Card $15,001-2017 30 revolving 2017 21% revolving 9. Gifts and Travel Reimbursements (N/A) - Not required for this type of report Endnotes PART # ENDNOTE 2. 1 Payments for personal services performed by filer are paid to this entity, including payments for television and radio hosting, syndicated columns, book authorship, board services, consulting work, and honoraria. Entities making such payments are reported in Part 1 to the extent filer was in a position associated with such an entity in 2016, 2017, or 2018; and Part 4 to the extent the entity paid more than $5000 for the filer's services in 2016, 2017, or 2018. In addition, each item of reportable intellectual property and each incidence of reportable honoraria received in 2017 or 2018 is specified here in Part 2 as a sub-entry to this income entry. Filer's role in the company ended upon government appointment; no further business is being conducted by the business and it is being wound down as a business entity. 2. 14 Cash account associated with filer's retirement account 5. 4 Cash account associated with spouse's retirement account Kudlow, Lawrence A - Page 13
Summary of Contents 1. Filer's Positions Held Outside United States Government Part 1 discloses positions that the filer held at any time during the reporting period (excluding positions with the United States Government). Positions are reportable even if the filer did not receive compensation. This section does not include the following: (1) positions with religious, social, fraternal, or political organizations; (2) positions solely of an honorary nature; (3) positions held as part of the filer's official duties with the United States Government; (4) mere membership in an organization; and (5) passive investment interests as a limited partner or non-managing member of a limited liability company. 2. Filer's Employment Assets & Income and Retirement Accounts Part 2 discloses the following: Sources of earned and other non-investment income of the filer totaling more than $200 during the reporting period (e.g., salary, fees, partnership share, honoraria, scholarships, and prizes) Assets related to the filer's business, employment, or other income-generating activities that (1) ended the reporting period with a value greater than $1,000 or (2) produced more than $200 in income during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and their underlying holdings as appropriate, deferred compensation, and intellectual property, such as book deals and patents) This section does not include assets or income from United States Government employment or assets that were acquired separately from the filer's business, employment, or other income-generating activities (e.g., assets purchased through a brokerage account). Note: The type of income is not required if the amount of income is $0 - $200 or if the asset qualifies as an excepted investment fund (EIF). 3. Filer's Employment Agreements and Arrangements Part 3 discloses agreements or arrangements that the filer had during the reporting period with an employer or former employer (except the United States Government), such as the following: Future employment Leave of absence Continuing payments from an employer, including severance and payments not yet received for previous work (excluding ordinary salary from a current employer) Continuing participation in an employee welfare, retirement, or other benefit plan, such as pensions or a deferred compensation plan Retention or disposition of employer-awarded equity, sharing in profits or carried interests (e.g., vested and unvested stock options, restricted stock, future share of a company's profits, etc.) Kudlow, Lawrence A - Page 14
4. Filer's Sources of Compensation Exceeding $5,000 in a Year Part 4 discloses sources (except the United States Government) that paid more than $5,000 in a calendar year for the filer's services during any year of the reporting period. The filer discloses payments both from employers and from any clients to whom the filer personally provided services. The filer discloses a source even if the source made its payment to the filer's employer and not to the filer. The filer does not disclose a client's payment to the filer's employer if the filer did not provide the services for which the client is paying. 5. Spouse's Employment Assets & Income and Retirement Accounts Part 5 discloses the following: Sources of earned income (excluding honoraria) for the filer's spouse totaling more than $1,000 during the reporting period (e.g., salary, consulting fees, and partnership share) Sources of honoraria for the filer's spouse greater than $200 during the reporting period Assets related to the filer's spouse's employment, business activities, other income-generating activities that (1) ended the reporting period with a value greater than $1,000 or (2) produced more than $200 in income during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and their underlying holdings as appropriate, deferred compensation, and intellectual property, such as book deals and patents) This section does not include assets or income from United States Government employment or assets that were acquired separately from the filer's spouse's business, employment, or other income-generating activities (e.g., assets purchased through a brokerage account). Note: The type of income is not required if the amount of income is $0 - $200 or if the asset qualifies as an excepted investment fund (EIF). Amounts of income are not required for a spouse's earned income (excluding honoraria). 6. Other Assets and Income Part 6 discloses each asset, not already reported, that (1) ended the reporting period with a value greater than $1,000 or (2) produced more than $200 in investment income during the reporting period. For purposes of the value and income thresholds, the filer aggregates the filer's interests with those of the filer's spouse and dependent children. This section does not include the following types of assets: (1) a personal residence (unless it was rented out during the reporting period); (2) income or retirement benefits associated with United States Government employment (e.g., Thrift Savings Plan); and (3) cash accounts (e.g., checking, savings, money market accounts) at a single financial institution with a value of $5,000 or less (unless more than $200 of income was produced). Additional exceptions apply. Note: The type of income is not required if the amount of income is $0 - $200 or if the asset qualifies as an excepted investment fund (EIF). 7. Transactions Kudlow, Lawrence A - Page 15
Part 7 discloses purchases, sales, or exchanges of real property or securities in excess of $1,000 made on behalf of the filer, the filer's spouse or dependent child during reporting period. This section does not include transactions that concern the following: (1) a personal residence, unless rented out; (2) cash accounts (e.g., checking, savings, CDs, money market accounts) and money market mutual funds; (3) Treasury bills, bonds, and notes; and (4) holdings within a federal Thrift Savings Plan account. Additional exceptions apply. 8. Liabilities Part 8 discloses liabilities over $10,000 that the filer, the filer's spouse or dependent child owed at any time during the reporting period. This section does not include the following types of liabilities: (1) mortgages on a personal residence, unless rented out (limitations apply for PAS filers); (2) loans secured by a personal motor vehicle, household furniture, or appliances, unless the loan exceeds the item's purchase price; and (3) revolving charge accounts, such as credit card balances, if the outstanding liability did not exceed $10,000 at the end of the reporting period. Additional exceptions apply. 9. Gifts and Travel Reimbursements This section discloses: Gifts totaling more than $390 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period. Travel reimbursements totaling more than $390 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period. For purposes of this section, the filer need not aggregate any gift or travel reimbursement with a value of $156 or less. Regardless of the value, this section does not include the following items: (1) anything received from relatives; (2) anything received from the United States Government or from the, state, or local governments; (3) bequests and other forms of inheritance; (4) gifts and travel reimbursements given to the filer's agency in connection with the filer's official travel; (5) gifts of hospitality (food, lodging, entertainment) at the donor's residence or personal premises; and (6) anything received by the filer's spouse or dependent children totally independent of their relationship to the filer. Additional exceptions apply. Kudlow, Lawrence A - Page 16
Privacy Act Statement Title I of the Ethics in Government Act of 1978, as amended (the Act), 5 U.S.C. app. 101 et seq., as amended by the Stop Trading on Congressional Knowledge Act of 2012 (Pub. L. 112-105) (STOCK Act), and 5 C.F.R. Part 2634 of the U. S. Office of Government Ethics regulations require the reporting of this information. The primary use of the information on this report is for review by Government officials to determine compliance with applicable Federal laws and regulations. This report may also be disclosed upon request to any requesting person in accordance with sections 105 and 402(b)(1) of the Act or as otherwise authorized by law. You may inspect applications for public access of your own form upon request. Additional disclosures of the information on this report may be made: (1) to any requesting person, subject to the limitation contained in section 208(d)(1) of title 18, any determination granting an exemption pursuant to sections 208(b)(1) and 208(b)(3) of title 18; (2) to a Federal, State, or local law enforcement agency if the disclosing agency becomes aware of violations or potential violations of law or regulation; (3) to another Federal agency, court or party in a court or Federal administrative proceeding when the Government is a party or in order to comply with a judge-issued subpoena; (4) to a source when necessary to obtain information relevant to a conflict of interest investigation or determination; (5) to the National Archives and Records Administration or the General Services Administration in records management inspections; (6) to the Office of Management and Budget during legislative coordination on private relief legislation; (7) to the Department of Justice or in certain legal proceedings when the disclosing agency, an employee of the disclosing agency, or the United States is a party to litigation or has an interest in the litigation and the use of such records is deemed relevant and necessary to the litigation; (8) to reviewing officials in a new office, department or agency when an employee transfers or is detailed from one covered position to another; (9) to a Member of Congress or a congressional office in response to an inquiry made on behalf of an individual who is the subject of the record; (10) to contractors and other non-government employees working on a contract, service or assignment for the Federal Government when necessary to accomplish a function related to an OGE Government-wide system of records; and (11) on the OGE Website and to any person, department or agency, any written ethics agreement filed with OGE by an individual nominated by the President to a position requiring Senate confirmation. See also the OGE/GOVT-1 executive branch-wide Privacy Act system of records. Public Burden Information This collection of information is estimated to take an average of three hours per response, including time for reviewing the instructions, gathering the data needed, and completing the form. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Program Counsel, U.S. Office of Government Ethics (OGE), Suite 500, 1201 New Avenue, NW., Washington, DC 20005-3917. Pursuant to the Paperwork Reduction Act, as amended, an agency may not conduct or sponsor, and no person is required to respond to, a collection of information unless it displays a currently valid OMB control number (that number, 3209-0001, is displayed here and at the top of the first page of this OGE Form 278e). Kudlow, Lawrence A - Page 17